Position Paper
25.03.2022 IOGP

IOGP response to Regulation on methane emissions reduction in the energy sector

This document provides IOGP's response to the ex-post consultation: Regulation on methane emissions reduction in the energy sector.

Context

IOGP supports the development of an EU-wide regulation addressing methane emissions aimed at contributing to climate neutrality by 2050. We agree with the European Commission’s objective to improve the accuracy of information about sources of methane emissions and to seek to reduce emissions.

In general, we are concerned that the Regulation in large parts establishes unnecessary measurement, verification, leak detection, reporting activities and new service industries with corresponding cost to the industry and consumers but with no environmental benefit, thereby not being in line with the Better Regulation principles.

IOGP is committed to contribute to further dialogue on the development of a fit for purpose Regulation of methane emissions and sharing our practices with other sectors tackling their methane emissions.

Key Points

  • With regard to the Monitoring, Reporting and Verification (MRV), the proposed Regulation in parts undermines the objective of the establishment of comparable global methane emission data
  • The proposed Regulation may even have adverse effects on the detection of methane emissions because of its very prescriptive approach to Leak Detection and Repair (LDAR) requirements
  • The broad definition of inactive wells may lead to MRV requirements on thousands of permanently plugged and abandoned offshore and onshore wells whilst not contributing to the Regulation’s objectives, but incurring significant cost to the industry and consumers
  • The definitions and use of the terms ‘venting’ and ‘flaring’ can be better aligned with those used by the World Bank's Global Gas Flaring Reduction Partnership (GGFR)
  • The text of the general mitigation obligation provides uncertainty as to the extent of the obligation and could result in numerous complaints raised in circumstances that might be immaterial